HomeMy WebLinkAbout00-02273
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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
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PENNA.
STATE OF
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CHERI L. THURBY.
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PLAINTIFF ,
VERSUS
SALVADOR DENIZARD, JR. ,
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DEFENDANT .
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AND NOW,
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No,
2000
2273
DECREE IN
DIVORCE
:r ~" den
, IT is ORDERED AND
DECREED THAT Cheri L. Thurbv
, PLAINTIFF,
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AND
Salvador Denizard. Jr.
, DEFENDANT,
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ARE DIVORCED FROM THE BONDS OF MATRiMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHtCH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
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None
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ATTEST:
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( PROTHONOTARY
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Michael S. Travis
ill No. 77399
4076 Market Street, Suile 209
Camp Hill, P A 17011
(717) 731-9502
v.
In the Court of Common Pleas of Cumberland County,
Pennsylvania
)
)
)
)
)
)
No, 00-2273
CHERI L. THURBY,
Plaintiff,
SALVADOR DENIZARD, JR.,
Defendant.
CIVIL TERM
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry of a
divorce decree:
1. Ground for divorce: irretrievable breakdown under 9 3301(d)(l) of the Divorce
Code.
2. Date and manner ofservice of the complaint: April 18, 2000, Affidavit of Service
attached hereto.
3. (a) Date of execution of the affidavit required by 9 3301(d) of the Divorce Code:
by plaintiff April 20, 2000; (b) Date of filing and service of plaintiff's affidavit upon the
respondent: May 17, 2000(filed), May 19, 2000(served).
4. Related claims pending: No economic claims were raised.
5. Date and manner of service of the notice of intention to file praecipe to transmit
record, a copy of which is attached: June 9, 2000, US Mail first class postage prepaid.
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Attorney for Plaintiff
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
CHERI L. THURBY,
Plain tiff,
)
)
)
)
)
)
No, 00 - 2273
vs,
SALVADOR DENIZARD, JR.,
Defendant,
CIVIL TERM
IN DIVORCE
NOTICE OF INTENTION TO REQUEST ENTRY
OF ~ 3301(d) DIVORCE DECREE
TO: SALVADOR DENIZARD, JR" DEFENDANT:
You have been sued in an action for divorce. You have failed to answer the complaint or
file a counter-affidavit to the ~ 3301(d) affidavit. Therefore, on or after June 30, 2000, the other
party can request the court to enter a final decree in divorce.
If you do not file with the prothonotary of the court an answer with your signature
notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in
divorce. A counter-affidavit, which you may file with the prothonotary of the court, is attached
to this notice.
Unless you have already filed with the court a written claim for economic relief, you
must do so by the above date or the court may grant the divorce and you will lose forever the
right to ask for economic relief. The filing of the form counter-affidavit alone does not protect
your economic claims.
YOU SHOULD TAKE TIDS PAPER TO YOUR LAWYER AT ONCE, IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHOl'o'E
THE OFFICE SET FORTH BELOW TO FIl'm OUT WHERE YOU CAN GET LEGAL
HELP,
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
SALVADOR DENlZARD, JR.,
Defendant.
)
)
)
)
)
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No, ~~-CJ2 73 of2000
CIVIL TERM
IN DNORCE
CHERI L, THURBY,
Plaintiff,
vs,
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set
forth in the following pages, you must take prompt action. You are warned that if you fail to do
so, the case may proceed without you and a decree of divorce or annulment may be entered
against you by the Court. A judgment may also be entered against you for any other claim or
relief requested in these papers by the Plaintiff. You may lose money or property or other rights
important to you, including custody or visitation of your children.
When the ground for divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Office of
the Prothonotary at:
Office of the Prothonotary
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, P A 17013
(717) 249-3166
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
CHERI L. THURBY,
Plaintiff,
SALVADOR DENIZARD, JR.,
Defendant,
)
)
)
)
)
)
No, (X)- J;;J 73
CIVIL TERM
IN DIVORCE
of 2000
vs.
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in divorce proceeding filed in the
Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance
with Section 3302( d) of the Divorce Code, you may request that the court require you and your
spouse to attend marriage counseling prior to a divorce being handed down by the court. A list
of professional marriage counselors is available at the Domestic Relations Office, 13 North
Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to
you and you are not bound to choose a counselor from this list. All necessary arrangements and
the cost of counseling sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty days of the date on which you receive this notice. Failure to do so will constitute a
waiver of your right to request counseling.
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
CHERI L. THURBY, )
Plaintiff, ) No. btJ- ;2,) 73
vs. ) of 2000
)
SALVADOR DENIZARD, JR., ) CIVIL TERM
Defendant. ) IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR
3301(d) OF THE DIVORCE CODE
Plaintiff, by her attorney Michael S. Travis, respectfully represents:
1. Plaintiff is Cheri L. Thurby, who resides at 1117 Columbus Avenue, Apt. 8,
Camp Hill, Cumberland County, Pennsylvania, 17011, since November, 1999.
2. Defendant is Salvador Denizard, Jr., who resides at HC04, Box 46755, Mayaguel,
Puerto Rico, 00680, for an undetermined period oftime.
3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for
at least six months immediately previous to the filing of this Complaint.
4. The plaintiff and defendant were married on February 10, 1998, at Honolulu,
Hawaii.
5. There have been no prior actions of divorce or annulment between the parties in
this or any other jurisdiction.
6. The marriage is irretrievably broken.
7. The parties have been living separate and apart. At a subsequent time, plaintiff
may submit an Affidavit that the parties have lived separate and apart for at least two (2) years.
8. Plaintiff has been advised that counseling is available and that plaintiff may have
the right to request that the court require the parties to participate in counseling.
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9. Although both plaintiff and defendant were previously in US Military Service,
neither plaintiff or defendant are currently in the Military Service in the United States Armed
Services. Neither plaintiff or defendant are within the provisions of the Soldiers' and Sailors'
Relief Act of Congress of 1940 and its amendments.
10. Plaintiff requests the court to enter a decree of divorce.
I verify that the statements made in this Complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. 9 4904, relating to
unsworn falsification to authorities.
Date: ~l-(\ - dO
/l-
Cheri L. Thurby,
Plaintiff
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Attorney for Plaintiff
J.D. # 77399
4076 Market Street, Suite 209
Camp Hill, P A 17011
(717) 731-9502
Fax 731-9511
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
)
)
)
)
)
)
ill
CBERIL. THURBY,
Plaintiff,
No.OO-2273
v.
SALVADOR DENIZARD, JR.,
Defendant.
CIVIL TERM
IN DNORCE
AFFIDAVIT OF SERVICE
.
I, Michael S. Travis, attorney for Plaintiff, in the above captioned action for divorce,
hereby state that a conformed and certified copy of the Complaint in Divorce was served upon
the Defendant by Certified Mail No. Z 352938890, return receipt requested, by depositing the
same in the United States mail on April 13, 2000, pursuant to Rille 1920.4 of the Amendments to
the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. As indicated by the
green return receipt card attached hereto, the Complaint was received by the Defendant on April
18,2000.
I verify that the statements made in this Affidavit are true and correct. I understand that
false statements herein are subject to the penalties of 18 Pa. C.S. g4904 relating to unsworn
falsification to authorities.
c ael S. Travis
4076 Market Street, Suite 209
Camp Hill, PA 17011
(717)731-9502
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[J prim 1,our name and address_on the reverse of this form s.O-that we can return this
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
CHERIL. THURBY,
Plaintiff,
)
)
)
)
)
)
No. 00.- 2273
CIVIL TERM
IN DIVORCE
vs,
SALVADOR DENIZARD, JR.,
Defendant.
NOTICE
If you wish to deny any of the statements set forth in this affidavit, you must file a
counter-affidavit within twenty days after this affidavit has been served on you or the statements
will be admitted:
AFFIDAVIT UNDER
SECTION3301(d) OF THE
DIVORCE CODE
1. The parties to this action separated on or before April 1 , 1998, and have continued to
live separate and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if! do not claim them before a divorce is granted.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18Pa.C.S. 94904 relating to unsworn
falsification to authorities.
Date: '-1-1b -00
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Cheri L. Thurby, PlaintIff
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